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SCOR is the fourth largest reinsurer in the world, with leading positions on its principal markets. SCOR is a global and diversified Tier 1 reinsurance group, aiming to develop its Life and P&C business lines, to provide its clients with value-added solutions and to pursue an underwriting policy based on profitability, through effective risk management and a cautious investment policy. In this way, SCOR offers its clients an optimal level of security (AA- rating from S&P and A+ rating from AM Best) and creates value for its shareholders. The Group’s strategy is based on a development model driven by three entities: the P&C entity, the Life entity and the Asset Management division.

For more information about the SCOR Group please refer to www.scor.com.

About Reinsurance

Reinsurance is a contract under which a company, the reinsurer, agrees to indemnify an insurance company, the ceding company, against all or part of the primary insurance risks underwritten by the ceding company under one or more insurance contracts.

Reinsurance differs from insurance primarily in terms of its inherent complexity, which is linked to its broader range of activities and international nature. Reinsurance can provide a ceding company with several benefits, including a reduction in net liability on individual risks and catastrophe protection from large or multiple losses. Reinsurance also provides ceding companies with the necessary capacity to increase their underwriting capabilities, in terms of both the number and size of risks. Reinsurance does not, however, discharge the ceding company from its liability to policyholders. Reinsurers themselves may feel the need to transfer some of the risks involved to other reinsurers (known as retrocessionnaires).

SCOR Global P&C Australia

Our Contribution to Australia

SCOR Reinsurance Asia Pacific Pte Ltd (Singapore entity), set up its Australia Branch (“SCOR Australia Branch”) since 1976. The principal business of SCOR Australia Branch is Property and Casualty reinsurance.

Other than SCOR Australia Branch, SCOR also has a Life reinsurance business, SCOR Global Life Australia Pty Ltd which was set up in 2011.

In Australia, insurance plays an important role in the society as it is a provision of risk management for the public as it is a loss prevention and risk sharing measures. Reinsurers, on the other hand, share the risks with the insurers as reinsurance provides three essential functions:

1.It offers the direct insurer greater security for its equity and solvency, as well as stable results when unusual and major events occur, by covering the direct insurer above certain ceilings or against accumulated individual commitments;

2.It allows insurers to increase their available capacity - i.e. the maximum amount they can insure for a given loss or category of losses, by enabling them to underwrite policies covering a larger number of risks, or larger risks, without excessively raising their administrative costs and their need to cover their solvency margin and, therefore, their shareholders' equity;

3.It makes substantial liquid assets available to insurers in the event of exceptional losses.

1.Defining their reinsurance needs and devising the most effective reinsurance program to better plan their capital needs and solvency margin;

2.Supplying a wide array of support services, specifically in terms of technical training, organisation, accounting and information technology;

3.Providing expertise in certain highly specialised areas such as the analysis of complex risks and risk pricing;

4.Enabling ceding companies to build up their business even if they are temporarily under-capitalised, particularly in order to launch new products requiring heavy investment.

ATO Public Disclosure 2015

SCOR is committed to an open and transparent relationship with our regulators and the governments in the countries in which we operate and conduct our business.

In respect of SCOR Australia’s income tax return (“ITR”) for the year ended 31 December 2015 (in lieu of the year ended 30 June 2016), the following details will be disclosed:

FY 2015

Total Income

A$

106,113,540

Taxable Income

A$

2,363,638

Income Tax Payable

A$

709,091.40

Total Income

Total Income is the amount shown at income Label 6S of the ITR represents gross income for accounting purposes ie. income before any expenses are taken into account. Total income is not an indicator of the real, economic or taxable profits of an organization. To illustrate this, set out below is a reconciliation of SCOR Australia’s total income to accounting profit for the year ended 31 December 2015:

FY 2015

Total Income

A$

106,113,540

Less: Total Expenses

A$

(92,895,762)

Profit/(Loss)

A$

13,217,778

Reconciliation of Profit to Taxable Income

A reconciliation of SCOR Australia’s accounting profit to taxable income for the year ended 31 December 2015, as reported in the ITR is set out below:

FY 2014

Book Profit/(Loss)

A$'m

13.2

Add:

Non-deductible Expenses

A$'m

0.52

Substract:

Income - Capital in Nature

A$'m

Non-assessable Income

A$'m

(11.4)

Taxable Income

A$'m

2.4

Tax @ 30%

A$'m

0.71

Effective tax rate

5%

As such, the effective tax rate for SCOR Australia for the year ended 31 December 2015 is 5% (being tax divided by accounting profit).

The effective tax rate of 5% is driven by the following adjustments:

1.Added back the general expenses accruals, accounting depreciation and other non-deductible expenses; and

2.Subtraction of the Outstanding Claims Reserve (“OCL”) of A$8.9m and other non-assessable income of A$2.5m. OCL is a provision made in the balance sheet of an insurance company for all claims that have been made and for which the insurer is liable, but which had not been settled at the balance sheet date).

Division 321 of the Income Tax Assessment Act 1997 (“1997 Act”) provides that an increase in an insurance company’s OCL for tax purposes are deductible and decreases in an insurance company’s OCL for tax purposes are assessable. Besides, ITAA 1997 requires OCL to be calculated on a discounted basis and exclude the direct and indirect settlement costs ie. the Actuarial basis.

However, SCOR Australia has not adopted the Actuarial basis for accounting purposes and compared with the Actuarial basis, there is a reduction of A$8.9m of the OCL movement which has been treated as an income through the profit and loss. As such, for income tax purpose, A$8.9m is subtract as non-assessable income.

SCOR Australia Branch paid income tax of A$0.7m in 2015. In addition, SCOR Australia Branch contributes in many ways to the Australian economy. In 2015, we:

Paid fringe benefits tax of A$0.04m ;

We collected and remitted to the ATO, GST of A$4.4m, A$1.3m in withholding tax on our reinsurance premiums to our reinsurers outside of Australia.

We recognize that our sustainable tax contributions are important to public finances and the funding of the social programs.

ATO Public Disclosure 2014

SCOR is committed to an open and transparent relationship with our regulators and the governments in the countries in which we operate and conduct our business.

In respect of SCOR Australia’s income tax return (“ITR”) for the year ended 31 December 2014 (in lieu of the year ended 30 June 2015), the following details will be disclosed:

FY 2014

Total Income

A$

121,200,332

Taxable Income

A$

0

Income Tax Payable

A$

0

Total Income

Total Income is the amount shown at income Label 6S of the ITR represents gross income for accounting purposes ie. income before any expenses are taken into account. Total income is not an indicator of the real, economic or taxable profits of an organization. To illustrate this, set out below is a reconciliation of SCOR Australia’s total income to accounting profit for the year ended 31 December 2014:

FY 2014

Total Income

A$

121,200,332

Less: Total Expenses

A$

(103,666,497)

Profit/(Loss)

A$

17,533,835

Reconciliation of Profit to Taxable Income

A reconciliation of SCOR Australia’s accounting profit to taxable income for the year ended 31 December 2014, as reported in the ITR is set out below:

FY 2014

Book Profit/(Loss)

A$'m

17.5

Add:

Non-deductible Expenses

A$'m

0.0

Substract:

Income - Capital in Nature

A$'m

Non-assessable Income

A$'m

(17.9)

Taxable Income

A$'m

-

Tax @ 30%

A$'m

0

Effective tax rate

0.0%

As such, the effective tax rate for SCOR Australia for the year ended 31 December 2014 is 0% (being tax divided by accounting profit).

The effective tax rate of 0% is driven by the adjustment (ie. a subtraction) of the Outstanding Claims Reserve (“OCL”) of A$17.9m. OCL is a provision made in the balance sheet of an insurance company for all claims that have been made and for which the insurer is liable, but which had not been settled at the balance sheet date).

Division 321 of the Income Tax Assessment Act 1997 (“1997 Act”) provides that an increase in an insurance company’s OCL for tax purposes are deductible and decreases in an insurance company’s OCL for tax purposes are assessable. Besides, ITAA 1997 requires OCL to be calculated on a discounted basis and exclude the direct and indirect settlement costs ie. the Actuarial basis.

However, SCOR Australia has not adopted the Actuarial basis for accounting purposes and compared with the Actuarial basis, there is a reduction of A$17.9m of the OCL movement which has been treated as an income through the profit and loss. As such, for income tax purpose, A$17.9m is subtract as non-assessable income.

As the adjustment of OCL movement is a timing difference, in 2013, SCOR Australia’s effective tax rate in 2013 was 70.2%. On average, it will be 32% which is slightly higher than the statutory rate of 30%.

FY 2013

FY 2014

Book Profit/(Loss)

A$'m

14.7

17.5

Add:

Non-deductible Expenses

A$'m

23.8

0.0

Substract:

Income - Capital in Nature

A$'m

(4.1)

Non-assessable Income

A$'m

(17.9)

Taxable Income

A$'m

34.4

-

Tax @ 30%

A$'m

10.3

0

Effective tax rate

70.2%

0.0%

Although SCOR Australia Branch does not pay any income tax in 2014, SCOR Australia Branch contributes in other ways to the Australian economy. In 2014, we:

Fringe benefits tax of A$0.1m ;

We collected and remitted to the ATO, GST of A$4.9m, A$1.5m in withholding tax on our reinsurance premiums to our reinsurers outside of Australia.

We recognize that our sustainable tax contributions are important to public finances and the funding of the social programs.

ATO Public Disclosure 2013

SCOR is committed to an open and transparent relationship with our regulators and the governments in the countries in which we operate and conduct our business.

In late 2015, the Commissioner of Taxation will publicly disclose the following details in respect of SCOR Australia Branch’s income tax return (“ITR”) for the year ended 31 December 2013 (in lieu of the year ended 30 June 2014):

FY 2013

Total Income

A$

149,361,127

Taxable Income

A$

34,446,335

Income Tax Payable

A$

10,333,900

Total Income

Total Income is the amount shown at income Label 6S of the ITR represents gross income for accounting purposes ie. income before any expenses are taken into account. In Reinsurance terminology, Total Income refer to the gross amount of premium collected before any payment for claims or any other expense. Total income is not an indicator of the real, economic or taxable profits of an organization. To illustrate this, set out below is a reconciliation of SCOR Australia Branch’s total income to accounting profit for the year ended 31 December 2013:

FY 2013

Total Income

A$

149,361,127

Less : Total Expenses

A$

(134,639,618)

Profit / (Loss)

A$

14,721,509

Reconciliation of Profit to Taxable Income

A reconciliation of SCOR Australia Branch’s accounting profit to taxable income for the year ended 31 December 2013, as reported in the ITR is set out below:

FY 2013

Book Profit/(Loss)

A$'m

14.7

Add:

Non-deductible Expenses

A$'m

23.8

Substract:

Income - Capital in Nature

A$'m

(4.1)

Non-assessable Income

A$'m

Taxable Income

A$'m

34.4

Tax @ 30%

A$'m

10.3

As such, the effective tax rate for SCOR Australia Branch for the year ended 31 December 2013 is approximately 70.2% (being tax divided by accounting profit).

The effective tax rate of 70.2% is much higher than the statutory tax rate of 30% is because of the tax adjustment (ie. an add-back) of the movement of the Outstanding Claims Reserve (“OCL”) of A$22.9m (included under “Non-deductible Expenses”). OCL is a provision made in the balance sheet of an insurance company for all claims that have been made and for which the insurer is liable, but which had not been settled at the balance sheet date. Since the A$22.9m was an accounting calculation (ie. not calculated by Actuary), it was disallowed for tax purposes. As such, there was an increase of taxable income and tax liability for the year ended 31 December 2013.

In addition to the above, SCOR Australia Branch also contributes in other ways to the Australian economy. In 2013, we:

We collected and remitted to the ATO, GST of A$5m and A$2m in withholding tax on our reinsurance premiums to our reinsurers outside of Australia.

We recognize that our sustainable tax contributions are important to public finances and the funding of the social programs.

SCOR Global Life Australia

Our Contribution to Australia

SGLA, commenced its Australia Reinsurance operation in 2011. The principal business of SGLA is Life Reinsurance including Death, Permanent and Temporary Disablement and Income Protection.

Other than the Life Company (SGLA), SCOR also has a Property and Casualty reinsurance business, SCOR Reinsurance Asia Pacific Pte Ltd which has a branch in Australia that opened in 1976.

In Australia, insurance plays an important role in the society as it is a provision of risk management for the public as it is a loss prevention and risk sharing measures. Reinsurers, on the other hand, share the risks with the insurers as reinsurance provides three essential functions

1.Reinsurance enables Life Insurers to transfer risk to reinsurers, who use Global scale to diversify their aggregate risk exposures, providing greater capacity to write more business and/or at larger limits and achieve cost benefits through economies of scale.

2.Reinsurers enable Life Insurers to reduce the amount of Capital needed to provide coverage, supporting Life Insurers by absorbing larger losses and making results more predictable

3.Reinsurers provide Life Insurers with specific specialised expertise and support services on Underwriting, Claims Management and Pricing, including training programs.

ATO Public Disclosure 2015

SCOR is committed to an open and transparent relationship with our regulators and the governments in the countries in which we operate and conduct our business.

In 2017, the Commissioner of Taxation has disclosed the following details in respect of SGLA’s income tax return (“ITR”) for the year ended 31 December 2015 (in lieu of the year ended 30 June 2015):

FY 2015

Total Income

A$

333,575,840

Taxable Income

A$

0

Income Tax Payable

A$

0

Total Income

Total Income is the amount shown at income Label 6S of the ITR and represents gross income for accounting purposes (ie. income before any expenses are taken into account). In Reinsurance terminology, Total Income refers to the gross amount of income collected before any payment for claims or any other expense. Total income is not an indicator of the real, economic or taxable profits of an organization. To illustrate this, set out below is a reconciliation of SGLA’s total income to accounting profit for the year ended 31 December 2015:

FY 2014

Total Income

A$

333,575,840

Taxable Expenses

A$

-336,909,728

Net Loss

A$

-3,333,888

SGLA has been operating in Australia since 2011, and continues to develop the necessary scale in the Australian market. In the start-up years of a life reinsurance business, acquisition costs, staff expenses and other operating expenses are higher than income, which will likely result in losses until such time as premium and investment incomes reach a critical mass sufficient to cover costs. Besides, to build its local franchise, a start-up reinsurer must underwrite and price at margins that are competitive against existing market participants.

Reconciliation of Profit to Taxable Income

A reconciliation of SGLA’s accounting profit to taxable income for the year ended 31 December 2015, as reported in the ITR is set out below:

FY 2014

Net Income/(Loss)

A$

(3,333,888)

Non-deductible expenses

A$

381,257

Tax losses carried forward to future years

A$

2,952,631

Net tax payable

A$

-

As such, the tax payable for the 2015 income tax year is zero and tax losses generated of $2,952,631 will be carried forward to offset with future year taxable profits.

Although SGLA does not pay income tax, SGLA contributes in other ways to the Australian economy. For the 2015 tax year, we paid withholding tax of $1.9 million and payroll tax of $0.2m. SGLA is also registered for GST and FBT.

We recognize that our sustainable tax contributions are important to public finances and the funding of the social programs.

ATO Public Disclosure 2014

SCOR is committed to an open and transparent relationship with our regulators and the governments in the countries in which we operate and conduct our business.

In late 2016, the Commissioner of Taxation has disclosed the following details in respect of SGLA’s income tax return (“ITR”) for the year ended 31 December 2014 (in lieu of the year ended 30 June 2014):

FY 2014

Total Income

A$

147,711,471.00

Taxable Income

A$

0.00

Income Tax Payable

A$

0.00

Total Income

Total Income is the amount shown at income Label 6S of the ITR and represents gross income for accounting purposes (ie. income before any expenses are taken into account). In Reinsurance terminology, Total Income refers to the gross amount of income collected before any payment for claims or any other expense. Total income is not an indicator of the real, economic or taxable profits of an organization. To illustrate this, set out below is a reconciliation of SGLA’s total income to accounting profit for the year ended 31 December 2014:

FY 2014

Total Income

A$

147,711,471

Taxable Expenses

A$

(151,350,571)

Net Loss

A$

(3,639,100)

SGLA has been operating in Australia since 2011, and continues to develop the necessary scale in the Australian market. In the start-up years of a life reinsurance business, acquisition costs, staff expenses and other operating expenses are higher than income, which will likely result in losses until such time as premium and investment incomes reach a critical mass sufficient to cover costs. Besides, to build its local franchise, a start-up reinsurer must underwrite and price at margins that are competitive against existing market participants.

Reconciliation of Profit to Taxable Income

A reconciliation of SGLA’s accounting profit to taxable income for the year ended 31 December 2014, as reported in the ITR is set out below:

FY 2014

Net Income/(Loss)

A$

(3,639,100)

Non-deductible expenses

A$

1,400,606

Tax losses carried forward to future years

A$

2,238,494

Net tax payable

A$

-

As such, the tax payable for the 2014 income tax year is zero and tax losses generated of $2,238,494 will be carried forward to offset with future year taxable profits.

Although SGLA does not pay any income tax, SGLA contributes in other ways to the Australian economy. In 2014, we paid withholding tax of $0.8 million and payroll tax of $0.1m. SGLA is registered for GST and FBT.

We recognize that our sustainable tax contributions are important to public finances and the funding of the social programs.